Official privacy document of the 39ss platform

Privacy Policy of 39ss – Your Data, Protected

39ss takes your data privacy seriously. This document clearly explains what we collect, how we use it, who we may share it with, and what your rights are as a data subject, in accordance with the General Data Protection Law (LGPD – Law No. 13,709/2018).

Last updated: January 2026

How 39ss Looks After Your Data

Six commitments that define our approach to privacy

LGPD Compliance

39ss processes the personal data of Brazilian players in full compliance with the General Data Protection Law. You have the right to know what we collect, why we collect it, and how your data is used.

Encryption on All Transactions

All data transmitted between your phone or computer and 39ss servers is protected by 256-bit SSL encryption — the same standard used by banks and financial institutions in Brazil.

Minimum Necessary Data Collection

39ss collects only the data strictly necessary to provide its services, perform identity verification (KYC), and meet its legal obligations. We do not sell personal information to advertisers or data brokers.

Your Rights, Guaranteed

You may at any time access, correct, request the portability of, or request the deletion of your personal data stored by 39ss, directly through your account dashboard or by contacting our support team.

Transparent Cookie Use

39ss uses strictly necessary cookies for the platform to function, and analytics cookies to improve the user experience. You can manage your cookie preferences at any time.

Communications You Control

39ss sends marketing communications only to users who have opted in. You can unsubscribe from promotional emails and push notifications at any time, without affecting your access to the platform.

This Privacy Policy applies to all services provided by 39ss accessed on the site, including Sports Betting, Live Casino, online poker, and all player account features. By using the 39ss platform, you confirm that you have read and understood how we handle your personal data as described below.

1About Us

39ss is a Sports Betting and online gaming platform focused on the Brazilian market, accessible at 39ss.best. For the purposes of this Privacy Policy, 39ss acts as both operator and controller of the personal data collected from its registered users in Brazil.

Our Data Protection Officer (DPO) can be reached by email at privacidade@39ss.best for matters related to personal data processing, the exercise of LGPD rights, or privacy complaints.

This policy was drafted in Portuguese and is governed by applicable Brazilian law, in particular Law No. 13,709/2018 (LGPD) and other regulations applicable to the online betting and entertainment sector in Brazil.

2Personal Data We Collect

2.1 Data you provide during registration

When you create an account on 39ss, you provide us directly with the following personal data:

  • Full name as it appears on your government-issued ID;
  • CPF (Cadastro de Pessoa Física);
  • Date of birth;
  • Email address;
  • Mobile phone number;
  • Full residential address (street, number, complement, neighborhood, city, state, ZIP code).

2.2 Identity verification data (KYC)

To meet its legal obligations regarding anti-money laundering and age verification, 39ss may request:

  • Copy of official government-issued photo ID (national ID card, driver's license, or passport);
  • Proof of residence issued within the last 90 days;
  • Selfie with document (liveness check) for biometric verification in specific cases;
  • Proof of ownership of the payment method used (when required).

2.3 Platform Usage Data

When you use 39ss, we automatically collect data about how you interact with the platform:

  • IP address and approximate geographic location;
  • Device type, operating system, and browser;
  • Betting history, games accessed, and financial transactions;
  • Date, time, and duration of sessions on the platform;
  • Pages visited and features used;
  • Cookie identifiers and similar technologies.

2.4 Financial Data

To process deposits and withdrawals, we record data related to your financial transactions on the platform, including the payment method used (Pix, credit/debit card, boleto bancário, PicPay, Mercado Pago), the amount, date, and status of each transaction. Full card details are processed by our PCI-DSS certified payment partners and are not stored in full on 39ss servers.

Note: 39ss does not collect health data, sexual orientation, religious beliefs, or any other sensitive data listed under Art. 11 of the LGPD, except where expressly required by law.

2.5 Support Communications

When you contact our support team via live chat, email, or WhatsApp, records of those conversations are stored for dispute resolution, service improvement, and legal traceability obligations.

3How We Use Your Data

39ss uses the personal data collected for the following purposes:

Purpose Data used
Player account creation and management Full name, CPF, email, mobile number, date of birth, address
Identity and age verification (KYC) Identity document, proof of address, selfie
Processing deposits and withdrawals via Pix, card, and other methods Financial data and Pix key
Fraud prevention and anti-money laundering CPF, IP address, transaction history, betting behavior
Customer support and dispute resolution Contact history, account data, betting records
Transactional communications (confirmations, security alerts) Email, mobile number
Marketing communications and promotions (with consent) Email, mobile number, gaming preferences
Personalized platform experience Betting history, favorite games, usage behavior
Compliance with Legal and Regulatory Obligations All data required under applicable legal obligations
39ss platform analysis and improvement Usage data, device data, platform behavior (anonymized)

39ss does not use your data for purposes beyond those listed above. If a new purpose becomes necessary, we will request your consent or inform you of the applicable legal basis.

4Legal Basis for Processing (LGPD)

The LGPD requires that personal data processing have a defined legal basis. 39ss processes your data under the following grounds set out in Art. 7 of the law:

  • Performance of a contract: to process your registration, bets, deposits, and withdrawals via Pix or other Brazilian payment methods — processing is necessary to provide the service you have contracted;
  • Compliance with a legal obligation: identity verification (KYC), anti-money laundering, and financial record retention as required by Brazilian law;
  • Legitimate interest: fraud prevention, platform security, analysis of suspicious behavior in Sports Betting and online poker, and improvement of the services we provide;
  • Consent: sending marketing communications, promotions, and personalized offers — you may withdraw this consent at any time without affecting your use of the platform.

Regarding consent: Withdrawing consent for marketing communications does not affect the provision of 39ss services, nor the processing of your bets and financial transactions, which are based on other legal grounds.

5Data Sharing

5.1 Who we may share data with

39ss does not sell personal data to third parties. Sharing only occurs in the situations below, always with appropriate data protection safeguards:

  • Payment processors: to process deposits and withdrawals via Pix, credit/debit card, boleto bancário, PicPay, and Mercado Pago. These partners are PCI-DSS certified and handle data solely for the purpose of processing the transaction;
  • Identity verification providers (KYC): specialized companies that assist with document verification and fraud detection as required by law;
  • Game providers: live casino, online poker, and slots providers that require minimal data for player authentication at the table;
  • Government and regulatory authorities: when required by law, court order, or a competent Brazilian authority;
  • Auditors and legal advisors: in internal audits, legal disputes, or regulatory proceedings, subject to confidentiality clauses;
  • Analytics and security services: analytics tools that help us detect fraudulent behavior and improve the platform experience, using anonymized or pseudonymized data wherever possible.

5.2 What we do not do

39ss does not share your personal data with data brokers, third-party advertising networks for retargeting purposes outside our platform, or any company without a direct relationship to the delivery of our services.

6Data Retention

39ss retains users' personal data for the period necessary for each purpose:

  • Active account data: retained for as long as the account remains active on the platform;
  • Data after account closure: retained for up to 5 years to meet legal obligations related to financial transactions, in accordance with Brazilian anti-money laundering legislation;
  • Betting and transaction records: retained for 5 years from the date of the transaction for legal and regulatory purposes;
  • KYC documents: retained for a minimum of 5 years after account closure, in accordance with regulatory requirements;
  • Support communication data: retained for 2 years for the resolution of potential disputes;
  • Analytics cookie data: retained for up to 13 months, as recommended by the ANPD.

Once retention periods expire, data is securely deleted or anonymized for statistical purposes, with no possibility of re-identification.

7Data Security

39ss implements appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or accidental destruction. Measures in place include:

  • 256-bit SSL/TLS encryption on all communication between your device and our servers;
  • Password storage with cryptographic hashing (never in plain text);
  • Two-factor authentication (2FA) available and recommended for all users;
  • Internal access controls based on the principle of least privilege — only staff with a legitimate need may access users' personal data;
  • Continuous monitoring for unauthorized access attempts and suspicious activity;
  • Regular security testing and vulnerability assessments;
  • Incident response plan with notification to the ANPD and affected data subjects in the event of a significant breach, in accordance with Art. 48 of the LGPD.

You also play an important role: choose a strong, unique password for your 39ss account, enable 2FA, never share your credentials, and contact support immediately if you suspect unauthorized access.

8Cookies and Similar Technologies

8.1 What are cookies

Cookies are small text files stored in your browser when you access the 39ss platform. They help us recognize you on return visits, keep your session active, and understand how the platform is used.

8.2 Types of cookies we use

  • Essential cookies: required for the platform's basic operation, such as keeping your session active and processing bets. These cannot be disabled without impairing use of the service;
  • Preference cookies: remember your platform settings, such as language, preferred odds, and display layout;
  • Analytics cookies: collect aggregated data on how users interact with the platform to help us identify improvements. Data is anonymized or pseudonymized;
  • Security cookies: help detect fraudulent behavior and protect your account.

8.3 Cookie Management

You can manage your cookie preferences at any time through your browser settings. Disabling essential cookies may affect how the 39ss platform functions. Disabling analytics and preference cookies will not impact the platform's core features.

9Your Rights as a Data Subject

The LGPD grants you, as the data subject whose personal data is processed by 39ss, the following rights, which you may exercise at any time through your account dashboard or by emailing privacidade@39ss.best:

Access

Request confirmation that we process your data and obtain a copy of the information we hold about you.

Correction

Request the correction of any incomplete, inaccurate, or outdated personal data in your account.

Deletion

Request the deletion of your personal data, subject to any legally required retention periods.

Portability

Receive your data in a structured, machine-readable format for transfer to another controller.

Objection

Object to processing based on legitimate interest or consent, with substantiated justification.

Information

Be informed about which entities 39ss has shared your data with and the purpose of each disclosure.

Upon receiving a request, 39ss will respond within 15 calendar days. For complex cases requiring further analysis, this period may be extended by the same amount of time, with notice provided to the data subject. 39ss does not charge fees to fulfill LGPD rights requests, except in cases of repetitive or manifestly unfounded submissions.

If you feel your rights have not been properly addressed, you may file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD), the authority responsible for overseeing LGPD compliance in Brazil.

10Minors

The 39ss platform is intended exclusively for users aged 18 and over. 39ss does not knowingly collect personal data from minors. If we become aware that a minor's data was collected without proper parental consent or in violation of applicable law, we will take immediate steps to delete that data and close the account.

Parents or guardians who suspect their minor children have created an account on 39ss should contact us immediately at privacidade@39ss.best with the information needed to verify and close the account.

Age verification: 39ss applies age verification procedures at registration and during the KYC process to ensure the platform is used exclusively by users aged 18 and over. Any account identified as belonging to a minor is closed immediately.

11International Data Transfers

In certain situations, processing your data may involve transferring it to countries outside Brazil — for example, when we use cloud infrastructure providers or identity verification partners with international operations.

39ss ensures that all such transfers are carried out with appropriate safeguards, including standard contractual clauses approved by the ANPD, transfers to countries recognized by the ANPD as providing adequate protection, or based on the data subject's specific consent, where applicable.

Financial data related to Pix transactions is processed exclusively in Brazil, by partners authorized by the Banco Central do Brasil (BACEN), with no international transfer.

12Changes to This Privacy Policy

39ss may update this Privacy Policy periodically to reflect changes in Brazilian legislation (including updates to the LGPD and ANPD regulations), our services, or our data processing practices.

Users will be notified of any significant changes at least 10 days in advance via their registered email and a prominent notice on the platform's homepage. The most up-to-date version of this policy is always available on this page, with the date of the last revision indicated at the top of the document.

Continued use of the 39ss platform after the change notice period constitutes acceptance of the updated Privacy Policy. If you do not agree with the changes, you may request account closure before the new terms take effect.

13Contact, DPO & Privacy Channel

To exercise your rights as a data subject, clarify any questions about this Privacy Policy, or file a complaint, please contact our Data Protection Officer (DPO):

  • Privacy email: privacidade@39ss.best
  • General support: suporte@39ss.best
  • Live chat: available on the 39ss platform, 24 hours a day

When reaching out through the privacy channel, please provide your full name, CPF (last four digits), the type of request you wish to make, and a clear description of your query. This helps us locate your data and respond accurately within the timeframe established by the LGPD.

For questions specifically related to betting, withdrawals, or platform functionality, please use our general support channel — the privacy channel is dedicated exclusively to data protection matters.

39ss is committed to protecting your personal data and to full compliance with the LGPD. If you have any questions not addressed by this policy, please do not hesitate to contact us. We also recommend reading our Terms & Conditions and the Responsible Gambling for a full overview of the platform's rules.

Your Data Safe, Your Fun Guaranteed at 39ss

Now that you know how we protect your data, create your 39ss account and enjoy betting on the Brasileirão, UFC, poker, and live casino with Pix deposits starting from R$ 10.00.

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